Neighbourhoods for a Sustainable Vancouver opposes the proposed recommendations in the summary dated March 17, 2011, the memorandum dated February 14, 2011, and staff policy report to Council dated December 17, 2010. We share the objections and grave reservations expressed by numerous individuals and organizations regarding these proposed height and rezoning policies for the Chinatown area.

We appreciate the extreme frustration of many Chinatown stakeholders, and especially the Family Societies, whose efforts to renovate buildings and redevelop property have been thwarted by forces largely beyond their control. The Chinatown Vision and Market Housing study prepared the way for a Community Plan to “engage the many organizations in Chinatown and the DTES to build consensus, foster community cohesion and work towards a common vision.” These initiatives called for “a comprehensive approach that includes community cultural and economic development and improvements to the public realm”; to “encourage the development of affordable rental housing,” while ensuring that that “additional height and mass are not visible from the street and there are no negative impacts on views and shadowing.”

But progress was blindsided by a group of big-time developers who had a very different vision. They attempted to exploit the Woodwards project as a precedent to clear the way for 300 to 400-foot towers throughout the Heritage Districts. Because of their influence, it was a close thing, but sanity prevailed. When the smoke cleared, however, rather than complete the community plan and start implementation, EcoDensity had been approved, along with Action B-1, the Historic Precincts Height Study, the intent of which was to provide replacement low-income housing, and/or to support other public benefits and amenities. Suitable, carefully considered locations, densities and heights will be determined through careful analysis and extensive public consultation to ensure the appropriate scale in the historic areas is maintained, while also being consistent with the City’s housing objectives for the area.” Unfortunately, the recommendations in this report fail to address these and other key objectives from the previous initiatives.

It has also come to light that many Chinatown stakeholders, especially residents and local merchants, have not been engaged in the process leading up to these current recommendations. Many are unaware of the proposed changes and their potential consequences. Residents of the adjacent Strathcona and Victory Square neighbourhoods also are significant stakeholders in the Chinatown area and need to be better included in the planning process.

We therefore request that the report and recommendations not be approved, and that height and development policies for Chinatown be considered within the context of a DTES community-wide planning process.

The current reports and recommendations, especially in regard to Chinatown South (HA-1A), raise many concerns. Besides objecting to the inadequate process, our main concerns are as follows.

The recommended permitted heights will increase demolition pressures on heritage and character buildings.

According to the report, “character” buildings are “encouraged to be rehabilitated.” These are empty words. .Allowing an additional storey on a low-rise rental building cannot compete with demolishing and replacing it with a 9-storey outright condo development. A difference of less than 30 feet between the proposed “outright” heights and heights that would be permitted subject to a rezoning in most of Chinatown South will result in very little “land lift” from which to extract public amenities or housing agreements.

Increasing the outright heights and densities will also up the ante in terms of generating Heritage Density as an incentive to preserve heritage buildings, putting additional pressure on the flooded Heritage Density Bank.

Changes to Transfer of Density policies increase development pressures.

Allowing Heritage Density to be transferred into Heritage Precincts is extremely problematic. The Transfer of Density policies were designed to remove development pressure from the Heritage Precincts by allowing density to be transferred out of the area–but not back in. What is being considered in Chinatown would go completely against this principle and allow density from other areas to be transferred into Chinatown South.

Mayor Robertson, this proposed change in policy is in violation of the commitment that you and nine other members of the current Council made during the 2008 election when you agreed to “oppose the transfer of density from the downtown Heritage Density Bank onto landing sites outside of the currently-approved areas.” It is a serious violation, not only because it is a breach of faith, but because it would contribute to the further mismanagement of this program, which has been distorted and rendered dysfunctional by upzoning of the Heritage Districts starting in 2003, and its inappropriate use as a major instrument for financing the Woodwards Project. Council needs to face up to this. Further outright increases in height and density in the Heritage Precincts, and landing heritage density in Chinatown South will exacerbate these problems

Few, if any, local amenities will be provided to serve the expanded population.

The report is vague and inadequate in regard to provision of amenities. The changes to Transfer of Density policies would remove or reduce options for Community Amenity Contributions (CACs) or other public benefits in the H1-HA area because the heritage density transfer becomes the amenity. Widespread objections have been voiced to Council’s “urgent” motion that severed Chinatown from the rest of the DTES, and this proposal divides Chinatown in two; the north that is subject to relatively modest impacts and social disruption while receiving the amenity, and the south, whose scale and livability are compromised, residents dislocated and businesses lost to provide those meager benefits. Similarly, residents who are fortunate to live in Family Society buildings may get their rooms upgraded, while their less lucky neighbours have no comparable protection, and may be relegated to shelters or the street

Demolition of heritage buildings will lead to loss of affordable rental housing.

Increasing development will mean that existing low income residents will be displaced as affordable rental housing in heritage buildings is demolished. Condo development in the Victory Square area has shown that as new condo market developments are built, they put upward pressure on rental rates which displaces low income tenants. We also share the well-founded concerns of CCAP, DNC and other advocates for low-income residents that this proposal is not linked to a viable strategy to provide new low-cost housing to replace what is lost.

Increased development in the area will increase business property taxes paid by the tenants. This will result in displacement of local businesses.

The proposed development would be out of scale with the heritage character.

The report is misleading in respect to the existing built environment of Chinatown. For example, in the HA-1A area only one or two heritage or “character” buildings fit the description of a “prominent streetwall height” of 70 feet. Other historic-era buildings are considerably lower; most have fewer than 4 storeys. The existing newer buildings in the 7 to10-storey range are not in character with this Heritage District, and adding an unlimited number of buildings of similar or greater height will, despite the use of irregular rooflines and stepbacks, serve to further erode the area’s historic character and pedestrian appeal. We support the concerns and suggestions in regard to these issues that were raised by Mr. Villegas ofThe Institute for Environmental Learning at Simon Fraser University.

Shadowing impacts on livability could be substantial.

Shadow impacts are only discussed in general terms. The report includes no shadow studies for the public realm and fails to acknowledge the negative impacts that development based on these policies would have on the streetscape. For example, 150-ft towers on the west side of Main would eliminate sunshine from both sides of the streetscape during the afternoon and early evening hours most of the year. New buildings ranging from 90 to 150 ft on the south sides of Keefer and Georgia Streets would have similar impacts, reducing access to daylight and sky under all weather conditions. The resulting canyon effect would be unpleasant for area residents and counterproductive in terms of attracting visitors and repeat shoppers because it would detract from the cheery, colourful street scene that is a vital ingredient of the Chinatown experience.

Shadow impacts from redevelopment on neighbouring buildings are given low priority, which essentially means they will not be considered. The homes of many Chinatown residents have but one room and one window. Many residents are elderly or infirm and spend much time at home. Buildings of the heights contemplated could therefore have profoundly negative impacts on the quality of life of residents, especially those whose homes are on lower storeys or face laneways.

Building heights could continue to rise.

It has come to our attention that community groups and individuals in Chinatown and other DTES neighbourhoods that are not comfortable with this proposal have been advised to support it because it will supposedly create certainty, and if it is not approved the influence of the development industry on planning policy and development decisions is such that in the near future area residents could instead be faced with proposals for 20 to 40-storey towers. This is worrisome because, even if well-meant, it is a message that encourages planning based on fear and coercion.

It also raises the concern that even if these proposed height increases were approved there are no guarantees that the limits will be respected. It would just mean the threshold that is negotiated from is higher. Every time the City upzones the Heritage Districts, the expectations of property owners and developers are raised even further. Instead, serious consideration should be given to reducing the outright permitted heights for these districts. There is little evidence that this plan will facilitate the “revitalization” of Chinatown.

Erosion of human scale and historic character could discourage tourism and impede revitalization. Two decades ago it was thought that the cure for Chinatown’s commercial decline was to construct a number of multi-storey parking garages. Now, the proposed cure is to drastically increase population density in Chinatown. But one need only look at the new condos in Chinatown South, and numerous towers within a few minutes walk of Chinatown, to see that insufficient density is not a problem. Residential development planned for North East False Creek will put additional residents within walking distance, and If some of the land reclaimed from the viaducts bordering Chinatown is developed for housing affordable to low -income families, this too will increase patronage for many area businesses.

Property tax increases will drive out local businesses.

In an area undergoing rapid demographic and cultural change it takes time for the business mix to adapt, but this is clearly beginning to happen. Chinatown has enough storefronts to increase diversity while maintaining competition. There are legitimate concerns, however, that permitting too great and too rapid redevelopment within Chinatown and the DTES will, through a combination of demolition, property tax and rent hikes, drive out too many of the businesses that primarily serve the area’s low-income residents, as well as the low-income shoppers who currently access these businesses on transit. Loss of character, culture and social equity through development-induced gentrification would be Vancouver’s loss, and we are very concerned that this is where the proposed rezoning policy would lead. These are some of the reasons that we think the Downtown Eastside Neighbourhood Council (DNC) and Building Community Society (BCS) are correct in calling for these rezoning proposals be scrutinized in the context of a Community Plan and Social Assets Review.

In conclusion:

The policies proposed here are typical of those stemming from the EcoDensity Initial Actions, which turn a blind eye to unintended consequences, place too little emphasis on affordability and livability, and are unworthy of Vancouver’s reputation for comprehensive community planning. In 2008, ten members of this current Council pledged to “support an extension of the EcoDensity public process to address outstanding concerns related to the EcoDensity Initial Actions and their implementation.” Your term is nearly up, yet you have failed to act on this commitment, along with numerous others that you made in the area of community planning.

Many other cities have found ways to protect their heritage and history without severely encroaching on scale, character and livability. Manhattan would not contemplate the mass upzoning of Greenwich Village, even though it would make developers and some property owners ecstatic. Toronto is not upzoning Kensington Market. Approving this proposal, which would be destructive of the scale and character of this historic area, with unmitigated and potentially devastating social impacts to its most vulnerable residents and many businesses, would not speak well of Vancouver, or our commitment to these values

We therefore request that issues relating to building height, density and development policy for Chinatown be addressed as part of a comprehensive community planning process for the DTES. By acknowledging Chinatown’s inescapable geographic, cultural and economic links to Vancouver’s other oldest neighbourhoods, by welcoming the input and serving the interests of all of the Chinatown and DTES stakeholders, and by working under the guiding principle of CityPlan—community involvement in decision making –we can do the best that we are capable of doing, while becoming a more conscious, creative and caring city.

Sincerely,Ned Jacobs
On behalf of the Steering Committee
Neighbourhoods for a Sustainable Vancouver